Case Law Update November 2025
Pinellas County Transit Authority/Commercial Risk v. Williams Jackson, ___ So.3d ___ (Fla. 1st DCA 11/12/25)
Compensability/Misrepresentation/Multiple Accidents
The claimant reinjured her shoulder in 2022, having originally injured the same shoulder with the same employer in 2021. The E/C denied compensability of the 2022 DOA based upon MCC, and because the JCC previously found the claimant made misrepresentations in her 2021 claim. The DCA affirmed the JCC’s award of benefits as to the 2022 claim. The DCA noted that the MCC analysis was inapplicable, as there was no contributing work-related cause. They also distinguished her case from prior cases where, although there was a prior work injury, no benefits had been sought (never deemed “compensable”). The DCA found the E/C’s misrepresentation analysis conflated “compensability” and “entitlement to benefits” which they deemed to be distinct concepts. They distinguished the 2021 finding of misrepresentation and the denial of benefits, finding it did not alter the initial 2021 injury’s initial compensable determination. They deemed the misrepresentation denial as only foreclosing benefits for the 2021 date of accident. They affirmed the JCC’s finding that the 2022 accident was not a ruse to resurrect benefits under the denied claim. Click here to view Opinion